On December 14, 2016, the Pipeline and Hazardous Materials Safety Administration (PHMSA) issued an Interim Final Rule (IFR or Rule) addressing critical safety issues related to downhole facilities, including wells, wellbore tubing, and casing, incorporated in underground natural gas storage facilities. This Rule will impose significant new requirements on operators of underground natural gas storage facilities, and will require compliance in a compressed time frame. PHMSA has described the IFR as a “first step” in improving safety that enables PHMSA to commence inspection and enforcement activities focused on underground natural gas storage facilities as soon as the rule is effective.

PHMSA’s IFR responds to Section 12 of the Protecting our Infrastructure of Pipelines and Enhancing Safety Act of 2016 (PIPES Act), which requires PHMSA to issue regulations imposing safety-related requirements on underground natural gas storage facilities within two years of enactment. Congress added this provision of the PIPES Act in response to the unprecedented 2015-16 leak experienced at the Aliso Canyon natural gas storage facility in southern California.